General Rule in Nontaxable Liquidation of a Subsidiary 1.
Tax Basis and Holding Period to Parent of Property Received in Liquidation of a Subsidiary A.
The Portfolio identifies issues arising in the context of deemed liquidations, and the special problems that can occur as a result of the interplay of the liquidation provisions with the S corporation rules and the consolidated return regulations.
The Portfolio also discusses the relationship between the liquidation rules and §338 (the election to treat a stock purchase as a purchase of assets).
Liquidating Distribution to Preferred But Not to Common Stock - Spaulding Bakeries, Inc. Subsidiary Not Taxable if § 332 Applies to the Liquidation b.
Tax Consequences to Parent on Liquidation of Insolvent Subsidiary a. Qualification of an Insolvent Subsidiary for a Nontaxable Liquidation D. Determining Whether a Taxable Liquidation Is Advantageous 2. Consequences Before Liquidation if Parent Acquires Debt from Unrelated Party c. Consequences to Subsidiary of Repayment of Debt to Parent a.
Application of Collapsible Corporation Rules to Minority Shareholders 5. Tax Consequences to Liquidating Subsidiary of Distributions to Minority Shareholders 1.
Prior Ownership of Target Stock by Acquirer - Elimination of the â€œBausch & Lombâ€ Rule 4. Distribution Solely of Cash Qualifies as â€œPropertyâ€ E. Subsidiary Liquidations Not Qualifying Under § 332 A. Section 269(b): Liquidation of Recently Purchased Subsidiary 5. Section 382: Limitation on Loss Carryovers and Built-In Losses 4. Deduction of Organizational, Liquidation, and Dissolution Expenses 1. Tax Management Portfolio, Corporate Liquidations, No. 784-3rd, analyses the tax considerations in connection with the liquidation of a corporation. Evolution of the Tax Treatment of Corporate Liquidations B.